A Digital Product Passport (DPP) is required for nearly every physical product placed on the EU market — and at least seven EU regulations now mandate some form of product passport or digital data sharing: the ESPR, Battery Regulation, Critical Raw Materials Act, Construction Products Regulation, Detergents Regulation, Toys Regulation, and End-of-Life Vehicles Regulation. Some products (like e-bikes with batteries and permanent magnets) fall under multiple regulations simultaneously. The only excluded categories are food, feed, medicinal products, and a narrow set of other items — everything else is covered.
This guide is a reference for determining which products are covered, which regulations apply, and what the current timelines look like.
Which Products Need a Digital Product Passport?
The ESPR applies to almost all physical products placed on the EU market. This scope is a dramatic expansion from the predecessor Ecodesign Directive (2009/125/EC), which only covered energy-related products like washing machines and light bulbs.
Under the ESPR, covered products include:
- Final products — textiles, furniture, electronics, tyres, mattresses, detergents
- Intermediate products and components — parts and materials that go into finished goods
- Products manufactured in the EU — domestic production is not exempt
- Products imported into the EU — from any third country, regardless of brand size
The scope expansion to components and intermediate products is significant. A fabric supplier, a battery cell manufacturer, or a steel producer may each face DPP obligations independently of the finished product they feed into.
For a deeper explanation of what a DPP is and how it works, see our complete guide.
What Products Are Excluded from ESPR?
Article 1 of the ESPR excludes a narrow set of product categories:
| Exclusion Category | Examples |
|---|---|
| Food and feed | All food products, animal feed |
| Medicinal products | Human and veterinary medicines |
| Living organisms | Plants, animals, micro-organisms |
| Products of human origin | Blood, tissues, organs |
| Plant and animal reproduction materials | Seeds, embryos |
| Defense and national security | Military equipment (sole-use) |
| Certain vehicles | Covered by separate End-of-Life Vehicles regulation |
If your product is not on this list, assume it will eventually need a DPP. The question is not "if" but "when" — determined by your product category's delegated act. The ESPR framework is already in force; product-specific requirements roll out through delegated acts over the coming years.
DPP Requirements Across 7+ EU Regulations
The ESPR is the broadest DPP mandate, but it is not the only one. At least seven EU regulations now require Digital Product Passports or equivalent digital data sharing. This table is the centerpiece of this guide — bookmark it for reference.
| Regulation | Products Covered | DPP Requirement | Timeline | Status |
|---|---|---|---|---|
| ESPR (EU 2024/1781) | Textiles, furniture, tyres, mattresses, iron/steel, aluminium, electronics | Full DPP with QR code, machine-readable data, EU registry | Textiles: ~2027-2028; Iron/steel: 2026-2027; Furniture: 2028-2029 | In force (July 2024); delegated acts pending |
| Battery Regulation (EU 2023/1542) | EV batteries, industrial batteries >2 kWh, LMT batteries | Battery passport with QR code — ID, performance, carbon footprint, recycled content, due diligence | Feb 18, 2027 (batteries >2 kWh); due diligence: Aug 2027 | In force; technical infrastructure developing |
| Critical Raw Materials Act (EU 2024/1252) | Motor vehicles, e-bikes, MRI devices, wind generators, electric motors, heat pumps, household appliances | Permanent magnet labeling + unique ID + composition/location/removal guidance | Disclosure: May 2027; Recyclability: May 2029 | In force (May 2024) |
| Construction Products Regulation (EU 2024/3110) | All construction products on EU market | Unique ID (GS1 GTIN), Declaration of Performance, safety, environmental data | ~2027-2028 (18 months after infrastructure completion) | In force (Jan 2025); infrastructure in development |
| Detergents Regulation (proposed, COM/2023/217) | All detergent products and surfactants | Physical data carrier + ingredient transparency + environmental impact | ~2027-2028 (~42 months after entry into force) | Council approved December 2025; awaiting Official Journal publication |
| Toys Regulation (EU 2025/2509) | All toys marketed in the EU | Product IDs, CE marking, certifications, allergen disclosures, safety warnings | Application from August 2030 | Adopted; in force January 2026 |
| End-of-Life Vehicles (proposed, COM/2023/451) | All vehicles placed on EU market | Environmental Vehicle Passport — CO2, energy, battery health, recyclability | TBD (~72 months after entry into force) | Provisional agreement reached December 2025; formal adoption pending |
This table represents the current state as of February 2026. Delegated act timelines have already slipped — the first ESPR delegated acts were planned for late 2025 and are now expected mid-2026. The Battery Regulation timeline is confirmed, but other categories should be treated as estimates. Monitor official EU sources and check the ESPR timeline for the latest updates.
What Happens When a Product Faces Multiple Passport Requirements?
Some products fall under more than one EU regulation requiring digital data sharing. These products face compounding compliance obligations — potentially needing data from multiple frameworks in a single passport or separate passports for different components.
| Product | Regulations That Apply | Overlapping Requirements | Practical Implication |
|---|---|---|---|
| Electric vehicle (EV) | Battery Regulation + End-of-Life Vehicles Regulation + ESPR (potentially) | Battery passport (cell chemistry, SoH, carbon footprint) + Environmental Vehicle Passport (CO₂, recyclability) + potential ESPR product passport | Multiple passports required for different components; data coordination across OEM and battery manufacturer |
| E-bike / e-scooter | Battery Regulation (LMT batteries) + ESPR + Critical Raw Materials Act (if permanent magnet motor) | Battery passport + potential ESPR product passport + permanent magnet composition/recyclability data | Three regulatory frameworks may apply to a single product |
| Connected home appliance (e.g., smart washing machine) | ESPR + Critical Raw Materials Act (permanent magnets in motors) + existing Energy Labelling Regulation | ESPR product passport + CRM permanent magnet labeling + energy label data | DPP must incorporate or reference existing energy label data |
| Textile with electronic component (e.g., heated jacket) | ESPR (textiles) + ESPR (electronics) + Battery Regulation (if rechargeable battery) | Textile composition data + electronic component data + battery passport for power source | May need DPP covering textile composition AND electronic/battery component data |
| Detergent in plastic packaging | Detergents Regulation + ESPR (potentially for packaging) | Detergent ingredient transparency + potential packaging composition/recyclability data | Separate data requirements for product contents and packaging material |
| Construction product with steel | Construction Products Regulation + ESPR (iron/steel delegated act) | CPR Declaration of Performance + ESPR steel passport data (recycled content, carbon footprint) | Two regulatory frameworks with potentially overlapping data fields |
If your product falls under more than one regulation in the table above, start compliance planning earlier than single-regulation products. The data coordination across multiple frameworks — potentially involving different standards, different registries, and different compliance timelines — adds complexity that compounds quickly. Identify which regulations apply to your product now, and map the data requirements from each before selecting a DPP platform.
For brands unsure which regulations apply to their specific products, our Readiness Checker identifies all applicable frameworks and gives you a prioritized action plan.
Do I Need a DPP If I Sell on Amazon, Etsy, or Shopify?
Yes — if you sell products in the EU market that fall under a DPP-requiring regulation, regardless of which platform you use.
ESPR Articles 35-36 impose specific obligations on online sellers and their service providers:
| Actor | Obligation Under ESPR |
|---|---|
| Online marketplace providers (Amazon, eBay, Etsy) | Must not allow non-compliant products to be listed; must cooperate with market surveillance authorities |
| Fulfilment service providers (Amazon FBA, 3PL warehouses) | If no EU-based economic operator exists in the chain, the fulfilment provider may assume importer obligations — including DPP compliance |
| Direct-to-consumer sellers (Shopify stores, own websites) | Must ensure DPP compliance for any product placed on the EU market |
A fulfilment service provider is defined as "any natural or legal person offering, in the course of commercial activity, at least two of: warehousing, packaging, addressing and dispatching, without having ownership of the products."
The practical implication: if you are a US-based brand selling via Amazon FBA into the EU, and your products fall under a DPP category, either you or your fulfilment provider must ensure compliance. Amazon has a pattern of enforcing compliance requirements ahead of regulatory deadlines to limit its own liability — expect DPP verification to follow the same path.
If you sell on Amazon EU, Etsy EU, or through Shopify to EU customers, start researching your product category's DPP timeline now. Marketplace enforcement will tighten as delegated acts take effect. Platforms may require DPP proof as a listing condition before the official regulatory deadline. See our guide on DPP penalties and enforcement for what non-compliance looks like in practice.
Do Non-EU Sellers Need a DPP?
Yes. ESPR Recital 63 states explicitly that "products from non-EU countries will equally need to comply."
The ESPR requires an EU Responsible Person — an authorized representative established in the EU who takes responsibility for the product's compliance. For non-EU manufacturers:
| Requirement | Details |
|---|---|
| EU Responsible Person | Must be designated before placing products on the EU market |
| DPP data responsibility | Responsible Person's details must be included in the DPP |
| Importer verification | Importers must verify product compliance including DPP data |
| Customs enforcement | Products without valid DPP registration can be detained at EU borders |
This applies equally to a Chinese manufacturer exporting textiles, an American electronics brand selling into Germany, or a Turkish furniture maker supplying EU retailers. Country of origin does not create an exemption — the obligation follows the product, not the manufacturer's location.
What About Second-Hand and Used Products?
The ESPR applies to used and second-hand products imported from a third country into the EU. The key distinction:
| Scenario | DPP Required? |
|---|---|
| Product already on the EU market, resold secondhand domestically | Existing DPP (if created when first placed on market) transfers with the product |
| Used product imported INTO the EU from outside | May need a DPP depending on the product category |
| Vintage/antique items pre-dating ESPR | Generally not covered retroactively |
"Placing on the market" means the first making available of a product on the EU market (ESPR Article 2(40)). A used jacket shipped from the US to a buyer in France is being "placed on the market" for the first time — and depending on the product category's delegated act status, it may require a DPP.
This has significant implications for resale platforms, vintage importers, and cross-border secondhand marketplaces operating in the EU.
Are Small Businesses Exempt?
No. There is no SME exemption from DPP requirements under ESPR.
This is one of the most misunderstood aspects of the regulation. Some industry analyses suggest SMEs "benefit from exclusion" — but this refers to specific narrow provisions, not the DPP obligation itself.
| ESPR Provision | SME Treatment |
|---|---|
| DPP requirements | No exemption — full compliance required regardless of company size |
| Destruction ban for unsold goods | Micro and small enterprises: fully exempt; medium enterprises: exempt until July 19, 2030 (Article 25) |
| Delegated act design | Commission may consider SME impact when setting requirements, but this does not create an exemption |
| Support measures | Member states must provide SME guidance, training, and financial assistance |
If you are a 5-person brand selling handmade leather goods into the EU, and leather goods fall under a DPP delegated act, you must comply. The timeline and specific data requirements are the same as for a multinational corporation. For an honest look at the challenges small brands face when preparing for DPP compliance, including cost and resource constraints, see our dedicated guide. For fashion brands specifically, our DPP guide for fashion covers practical preparation steps scaled for smaller teams.
When Does My Product Category Need a DPP?
This timeline table consolidates the best current estimates across all relevant regulations. Use the confidence column to gauge how firm each deadline is.
| Product Category | Expected DPP Deadline | Confidence Level |
|---|---|---|
| Batteries (>2 kWh) | February 2027 | Confirmed (regulation published) |
| Iron and steel | 2026-2027 | High (priority delegated act) |
| Aluminium | 2027-2028 | High (priority delegated act) |
| Textiles and footwear | 2027-2029 | Medium-high (preparatory study underway) |
| Tyres | 2027-2028 | Medium-high |
| Electronics | 2027-2029 | Medium (delegated act expected) |
| Construction products | 2027-2028 | High (regulation published) |
| Detergents | 2027-2028 | Medium (provisional agreement reached) |
| Furniture | 2028-2029 | Medium |
| Mattresses | 2029 | Medium |
| Toys | 2029-2030 | Medium-high (regulation adopted) |
| Vehicles | TBD | Low (proposal stage) |
Take the Next Step
Not sure where your brand stands? Here are your next steps:
- Check your DPP readiness — Free assessment that identifies which regulations affect your products and gives you a prioritized action plan
- Understand the real costs — Realistic breakdown of what DPP compliance costs for small brands
- See what a DPP actually looks like — Real examples from batteries, textiles, and construction with annotated data fields
- Follow proven best practices — 10 lessons from early adopters on implementation strategy
Frequently Asked Questions
Is the Digital Product Passport mandatory?
Yes, for products covered by ESPR delegated acts and other EU regulations like the Battery Regulation. The ESPR framework is already in force since July 2024, and product-specific requirements roll out via delegated acts. Battery passports are mandatory from February 2027, with textiles and electronics expected 2027-2029. Once a delegated act for your product category is published, compliance becomes legally required after the specified transition period.
Do Etsy sellers need a DPP?
If you sell physical products into the EU market that fall under a DPP-requiring regulation, yes — regardless of which platform you sell on. Etsy, Amazon, and other online marketplaces must enforce DPP requirements under ESPR Articles 35-36. The obligation is on whoever places the product on the EU market, which typically means the seller. The platform must also cooperate with market surveillance authorities and may not allow non-compliant listings.
Are second-hand products exempt from DPP requirements?
Not if they are being imported into the EU from a third country. Used products entering the EU market for the first time may need DPP compliance depending on the product category and whether a delegated act is in effect. Products already on the EU market that are resold domestically should carry their existing DPP. The key legal concept is "placing on the market" — the first time a product is made available in the EU.
What if my product fits multiple categories?
The delegated act for your primary product category applies. If your product has components that fall under different categories — for example, a piece of furniture with electronic components, or an electric bicycle with a battery — you may need to comply with requirements from multiple delegated acts. Each component or sub-assembly may need its own DPP data. Check the specific delegated acts for guidance on composite products once they are published.
When does my specific product category need a DPP?
It depends on when the delegated act for your category is published and its compliance deadline. Battery passports are confirmed for February 2027. Iron and steel are expected 2026-2027. Textiles are expected around 2027-2029. Use the quick-reference timeline table in this guide for the latest estimates, and monitor the ESPR timeline for updates as delegated acts are published.
What products are excluded from DPP requirements?
Food, feed, medicinal products (human and veterinary), living organisms, products of human origin, plant and animal reproduction materials, and products solely for defense or national security are excluded under ESPR Article 1. Certain vehicles are excluded from ESPR but covered by the separate End-of-Life Vehicles regulation. Every other physical product placed on the EU market falls within the ESPR's scope and will eventually require a DPP when its product category's delegated act takes effect.
